Privacy Policy

This Privacy Policy applies between you, the User of this Website, and Keys to Safeguarding Ltd, the owner and provider of this Website. Keys to Safeguarding Ltd takes the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. 

Please read this Privacy Policy carefully.

Keys to Safeguarding Ltd is committed to safeguarding your privacy. Contact us at team@keystosafeguarding.com if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you. We will keep the information you provide confidential at all times.

Keys to Safeguarding Ltd will not disclose your personal information outside the Group and Partner organisations. All personal information is handled in accordance with the United Kingdom’s data protection legislation.

This online privacy policy applies only to information collected through this website and not to information collected offline. By using this site or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy.

Our website address is: https://www.keystosafeguarding.com

Definitions and Interpretation

In this Privacy Policy, the following definitions are used:

Data: collectively all information that you submit to Keys to Safeguarding Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.

Personal Data: any information relating to an identified or identifiable person.

Processing: any operation or set of operations which is performed on Personal Data or on sets of Personal Data.

Data subject: a person whose Personal Data is being Processed.

Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies).

Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation.

GDPR: the UK General Data Protection Regulation.

Keys to Safeguarding Ltd, we or us: Keys to Safeguarding Ltd, a company incorporated in England and Wales with registered number 12475441 whose registered office is at Aston House Campbell Way Dinnington, Sheffield, South Yorkshire, S25 3QD.

UK and EU Cookie Law: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018.

User or you: any third party that accesses the Website and is not either (i) employed by Keys to Safeguarding Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Keys to Safeguarding Ltd and accessing the Website in connection with the provision of such services.

Website: the website that you are currently using, www.keystosafeguarding.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

In this Privacy Policy, unless the context requires a different interpretation:

• The singular includes the plural and vice versa.
• References to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy.
• A reference to a person includes firms, companies, government entities, trusts and partnerships.
• “Including” is understood to mean “including without limitation”.
• Reference to any statutory provision includes any modification or amendment of it.
• The headings and sub-headings do not form part of this Privacy Policy.

We promise to follow the following data protection principles:

• Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
• Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
• Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
• Processing is limited with a time period. We will not store your personal data for longer than needed.
• We will do our best to ensure the accuracy of Data.
• We will do our best to ensure the integrity and confidentiality of Data.

Data Subject’s rights

The Data Subject has the following rights:

1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
10. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.

If you have an account on this site, or have left comments, you can request to receive an exported file of the Personal Data we hold about you, including any Data you have provided to us. You can also request that we erase any Personal Data we hold about you. This does not include any Data we are obliged to keep for administrative, legal, or security purposes.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: team@keystosafeguarding.com.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

To request a copy of your Personal Data, please email team@keystosafeguarding.com and include your name, this website’s URL, and the email address previously used when submitting data. You can also request the deletion or anonymisation of your Data.

Data we gather

Data That is Given to Us by You

Keys to Safeguarding Ltd will collect your Data in a number of ways, for example:

• When you contact us through the Website, by telephone, post, e-mail or through any other means.
• When you register with us and set up an account to receive our products/services.
• When you make payments to us, through this Website or otherwise.
• When you elect to receive marketing communications from us.
• When you use our services.

In each case, data is collected and stored in accordance with this Privacy Policy.

Data That is Collected Automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

• We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
• We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, your shopping history (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

When you complete and submit a contact form, the data that you enter are sent to external email accounts and a copy is stored in the database of this website. The forms record live data and any information in completed fields is still stored – even if the form has not been completed and submitted. Data in forms that have not been completed and submitted are not sent off-site.

Learndash LMS

We collect information about you during the course purchase process (PayPal, Stripe, and/or 2Checkout), as well as information relating to your course progression and quiz performance.

When you purchase from us, we’ll ask you to provide email address. We’ll use this information for purposes, such as, to:

• Send you information about your account and order
• Create your account for our LMS
• If you register a free account then we will store your email address.
• We store information about you for as long as your account exists.
• We store course progress, including completion status, quiz scores, assignments and/or essay submissions (if applicable).
• We will also store comments on courses, lessons, topics, assignments, and essays if you choose to leave them.

Members of our team have access to the information you provide us. For example, both Administrators and Group Leaders can access:

• Order information such as your enrolled courses, course progress and username / email address.
• Any additional information added in your WordPress User Profile can also be visible to the administrator(s).

We share information with third parties who help us provide our orders and store services to you (e.g. WooCommerce, Stripe).

WooCommerce

We collect information about you during the checkout process on our store.

While you visit our site, we’ll track:

• Products you’ve viewed: we’ll use this to, for example, show you products you’ve recently viewed.
• Location, IP address and browser type: we’ll use this for purposes like estimating taxes and shipping.
• Shipping address: we’ll ask you to enter this so we can, for instance, estimate shipping before you place an order, and send you the order.
• We’ll also use cookies to keep track of basket contents while you’re browsing our site.

When you purchase from us, we’ll ask you to provide information including your name, billing address, shipping address, email address, phone number, credit card/payment details and optional account information like username and password. We’ll use this information for purposes, such as, to:

• Send you information about your account and order.
• Respond to your requests, including refunds and complaints.
• Process payments and prevent fraud.
• Set up your account for our store.
• Comply with any legal obligations we have, such as calculating taxes.
• Improve our store offerings.
• Send you marketing messages, if you choose to receive them.
• If you create an account, we will store your name, address, email and phone number, which will be used to populate the checkout for future orders.

We generally store information about you for as long as we need the information for the purposes for which we collect and use it, and we are not legally required to continue to keep it. For example, we will store order information for seven years for tax and accounting purposes. This includes your name, email address and billing and shipping addresses.

We will also store comments or reviews, if you choose to leave them.

Members of our team have access to the information you provide us. For example, both Administrators and Shop Managers can access:

• Order information like what was purchased, when it was purchased and where it should be sent.
• Customer information like your name, email address, and billing and shipping information.
• Our team members have access to this information to help fulfil orders, process refunds and support you.

WooCommerce Subscriptions

For the purposes of processing recurring subscription payments, we store the customer’s name, billing address, shipping address, email address, phone number and credit card/payment details (any payment details are stored by Stripe – our payment processor).

Stripe

We use Stripe as our payment processor. Your payment data is not stored on this website.

Information shared with a payment provider to process payments includes:

• Name
• Email
• Address
• Phone
• City/State/Zip
• Unique payment identifier
• Payment provider identifier

Stripe sets the following functional cookies:

wp_woocommerce_session_HASH
_stripe_mid
_stripe_sid

Further information on how Stripe saves and manages your data is available here.

Zoho CRM

KeysTo Safeguarding uses Zoho CRM to store Persaonl Data about a user’s account (name, email, etc.), user course progression, order status and purchases. The Data is created when the user interacts with WordPress, WooCommerce, WooCommerce Subscriptions, Stripe (excluding payment details) and Learndash LMS.

Please see the Zoho privacy policy for more details.

Litespeed Cache

This site utilises caching in order to facilitate a faster response time and better user experience.

Caching potentially stores a duplicate copy of every web page that is on display on this site. All cache files are temporary, and are never accessed by any third party, except as necessary to obtain technical support from the cache plugin vendor.

Cache files expire on a schedule set by the site administrator, but may easily be purged by the admin before their natural expiration, if necessary. We may use QUIC.cloud services to process & cache your Data temporarily.

Please see the QUIC.cloud privacy policy for more details.

How we use your Personal Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. 

We use your Personal Data in order to:

• Provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
• Enhance your customer experience.
• Fulfil an obligation under law or contract.
• Internal record keeping.

Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

We use your Personal Data on legitimate grounds and/or with your Consent.

On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:

• To identify you.
• To provide you a service or to send/offer you a product.
• To communicate either for sales or invoicing.

On the ground of legitimate interest, we Process your Personal Data for the following purposes:

• To send you personalised offers.
• To administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided.
• To conduct questionnaires concerning client satisfaction.

As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.

With your consent we Process your Personal Data for the following purposes:

• To send you newsletters and campaign offers (from us and/or our carefully selected partners).
• For other purposes we have asked your consent for.

We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. 

We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the Data was gathered. To do this, we will ensure that:

• The link between purposes, context and nature of Personal Data is suitable for further Processing.
• The further Processing would not harm your interests and
• There would be appropriate safeguard for Processing.

We will inform you of any further Processing and purposes.

Who else can access your Personal Data?

We do not share your Personal Data with strangers. Personal Data about you could be, in some cases, provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience.

We will only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We may disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.

How we secure your data

We do our best to keep your Personal Data safe.  We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks. We use a firewall to track and monitor login and visitor data, and secure the website from unauthorised access. This data consists of IP addresses, pages visited, login attempts, the date and time of your visit to the website, and details about the browser used to access the site.

Data processed by the firewall may be shared with Defiant, Inc. Privacy policy.

Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

If you have an account with us, note that you have to keep your username and password secret.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: team@keystosafeguarding.com.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Cookies and other technologies we use

This Website may place and access certain Cookies on your computer. Keys to Safeguarding Ltd uses Cookies to improve your experience of using the Website and to improve our range of products and services. Keys to Safeguarding Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Keys to Safeguarding Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

We use cookies and/or similar technologies to analyse customer behaviour, administer the website, track users’ movements, and to collect information about users. This is done in order to personalise and enhance your experience with us.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no Personal Data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no Personal Data and simply indicates the post ID of the article you just edited. It expires after 1 day.

We use some social sharing plugins, to allow you to share certain pages of our website on social media. These plugins place cookies so that you can correctly view how many times a page has been shared.

We use cookies for the following purposes:

• Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookies.
• Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.networkadvertising.org or opt out of targeted advertisements by visiting youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.

Please visit our Cookie Policy page for further information about cookies on this site and to manage your consent. 

Analytics

We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Links to Other Websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

When Keys to Safeguarding Ltd no longer has a legitimate business need to process your personal information, or no longer has a need to keep your personal information for any legal, tax, or regulatory reason, we will either delete or anonymise it.

Backups

Backups of the website files and/or database are created and stored locally on this server and remotely on 3rd party servers. Archives can include, but are not limited to, file and database assets, including hashed passwords, 3rd party data, uploads and user information.

Dates, times and actions of successful and unsuccessful backups and remote data transfers are tracked. This is stored to help make the backup service better and assist with troubleshooting problems.

Cookies are used to handle importing and restoring backups. Cookies used during the restore/import process expire after 24 hours.

Some plugin settings ask for an email address or login credentials to 3rd party services. This is stored to provide functional features to the plugin.

Backup services track dates, times and actions of successful and unsuccessful backups and remote data transfers. This is stored to help make the service better and assist with troubleshooting problems. These services log some personal information such as email addresses, usernames, database and server information. This is stored to help make the services better and assist with troubleshooting problems.

Backup zip files are stored with hashed file names to prevent filename guessing and directory browsing is disabled.

External storage providers:

Amazon S3: Privacy Policy
Google Drive: Privacy Policy
Blogvault: Privacy Policy

Changes of Business Ownership and Control

Keys to Safeguarding Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Keys to Safeguarding Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Supervisory Authority

The Information Commissioner’s Office 
Website: https://ico.org.uk
Email: info@ico.org.uk
Phone: +44 (0)303 123 1113

Changes to this Privacy Policy

Keys to Safeguarding Ltd reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations.  

You may contact Keys to Safeguarding Ltd by email at team@keystosafeguarding.com.

Last modification was made October 10, 2023.